What You Need to Know: CMS to Shorten 2015 Attestation Reporting Period

By now, you and your staff are probably quite familiar with the concepts and regulations of “meaningful use” (MU) of electronic health record (EHR) technology which has to be demonstrated in order for hospitals and eligible providers (EPs) to receive the incentive payments from the Centers for Medicare and Medicaid Services (CMS). You are probably also fully aware that there are specific criteria that has to be met and “attested” to in order to document that “meaningful use” has been achieved.

EHR Meaningful Use is defined by healthit.gov as technological techniques which:

Improve healthcare records-keeping efficiency, quality, and safety;
Increase efficiency of healthcare coordination with population health/public health offices;
Follow the federal Health Insurance Portability and Accountability (HIPAA) law; and
Maintain the integrity of the Patient Safety and Quality Improvement Act (PSQIA).

Meaningful Use incentives in your workplace should help effect:

Better clinical and population health outcomes.
Seamless transparency and efficiency,
Technician empowerment, and
Increased and more detailed health systems data.

Initially, hospitals and EPs had to document 100% compliance with the MU criteria for the minimum of a 90 consecutive day attestation period in the calendar year in which the incentive was being applied for. Over the years, since beginning in 2011, the requirements for the attestation period have been changed by the CMS. The attestation time was changed from 90 consecutive days to 365, and from using the calendar year – January through December – to that of the federal government fiscal year – October through September. Many hospitals and physicians have found these changes to be difficult to comply with.

The CMS, which oversees the EHR Incentive Payment programs, seemed unresponsive to providers’ pleas to change the reporting time, but took notice when members of Congress introduced legislation to that effect. “There wasn’t a lot of flexibility for 2015,” said CEO Russell Branzell of CHIME (College of Healthcare Information Management Executives). “This gives us a much better chance to participate in attestation for 2015.”

At the end of January this year The CMS Blog reported that they are intending to engage in rule making this spring that would:

Realign hospital EHR reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other CMS quality programs.
Modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens.
Shorten the EHR reporting period in 2015 to 90 days to accommodate these changes.

The time incentive and other CMS proposals are supposed to lessen providers’ reporting difficulties and to:

Give medical facilities and practices more time to transition the 2014 software into their current workflows,
More seamlessly transition the new software edition with other CMS programs, and
Enhance long-term goals while reducing complexity.

In March 2015, healthcare attorney and writer Marla Durben Hirsch shared information about recent studies on EHR Meaningful Use (MU) and how it has helped accelerate reporting. Hirsch also explained that the new-and-improved Medicare and Medicaid EHR incentive program would shorten the 2015 attesting reporting period from 365 to 90 days. This is a reprieve that many professionals and facilities needed to accommodate the program’s software implementation and information merge concerns.

While these changes to the attestation period would affect the 2015 reporting year, there is no guarantee that they would extend to 2016. So, if you have not attested to your initial or next available stage of MU, we at Healthcare Information Services (HIS) would be happy to meet with you and help guide you in the process.

What You Need to Know: CMS to Shorten 2015 Attestation Reporting Period